INCENTIVE PRIVACY NOTICE

Last Updated: July 13, 2020

PRIVACY NOTICE

Who We Are

What this Notice Cover

Defined Terms

Our Collection of Personal Information

Our Use of Personal Information

Our Disclosure of Personal Information

Communication Preferences

Region-Specific Disclosures

Children’s Privacy

Third Party Websites

Changes to This Notice

How to Contact Us

Your privacy is very important to us. This Notice explains how eMoney collects, uses, discloses, and otherwise processes personal information in connection with our mobile application, Incentive. We encourage you to read this Privacy Notice as well as the Incentive Terms of Service. Additionally, by using or registering for Incentive, you acknowledge that you have read and understand the terms of this Privacy Notice. If you do not agree with (i) this Privacy Notice, (ii) any revisions to this Privacy Notice, and/or (iii) any practices related to this Privacy Notice, do not use, visit, register, or otherwise access Incentive.

Who We Are

We are eMoney Advisor, LLC (“eMoney,” “our,” “we,” and/or “us”), a leading wealth management technology company that provides comprehensive, scalable financial planning software to financial firms and advisors. Our innovative technologies empower our clients to meet a broad range of planning needs for their customers.

What this Notice Covers

This Notice covers the personal information we collect through our mobile application, Incentive, that we own and operate and that links to this Notice (the “services”). We provide Incentive to financial advisors who administer 401(k) plans. These financial advisors use Incentive as a tool to help plan participants improve their financial wellness and meet financial goals.

Defined Terms

When we use the term “aggregate,” “aggregated,” or “aggregation,” we mean a process undertaken at the direction of the user to gather information from various sources, such as financial institution and financial accounts, to be consolidated into Incentive. “Aggregated information” is the information that is gathered together in one location through this aggregation process.

When we use the term “personal information” in this Notice, we mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, to you.

When we refer to “user(s)” or “you” in this Notice, we are referring to individual investors who receive access credentials to Incentive through participation in a 401(k) plan, from a financial advisor, or by signing up directly on the Apple App Store or Google Play Store.

Our Collection of Personal Information

Once you elect to use our services through your 401(k) plan sponsor, we begin collecting personal information about you. Sometimes we collect personal information automatically when you interact with our services and sometimes we collect the personal information directly from you. At times, we may collect personal information about you from other sources and third parties, even before our first direct interaction.

Image Personal Information You Provide

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Contact Information

Such as your first and last name, and email address

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Demographic Information

Such as your gender, sex, date of birth, and your age

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Account Information

Such as your account username and password, security or authentication information

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Financial Information

Such as your financial account numbers, passwords, transactions and purchase information, and balances, allocation and holding information, account history, and investment history

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Event Information

Such as your webinar enrollment information

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Survey Information

Such as your opinions and feedback on our services’ features

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Professional/Employment Information

Such as your employer, job title, and salary

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User Generated Content

To the extent it is personal information, such as your comments to other users

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Inquiry Information

Such as the content of your email, text, or chat with us and, where applicable, your voice from calls with us

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Log File Data

Including your IP address, device operating system, application software, browser type, peripheral devices, language, user log and clickstream data, access times, Active Directory information and the websites you visited before/after ours

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Cookies and Related Technology Data

Including your usage and activity on our online services, such as information relating to your orders, purchases and cart activity, using essential and non-essential cookies, web beacons and related data collection technologies

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Location Data

Including your general geographic location based on your IP address or more precise location when accessing our online services through a mobile device

For more information about cookies and related technologies, including on how to control your privacy settings, please read our Cookie Notice.

Image Personal Information from Other Sources and Third Parties

We also obtain personal information from other sources, which we often combine with personal information we collect either automatically or directly from you.

We receive the same categories of personal information as described above from the following sources and third parties:

We Collect Personal Information from Third Parties Involved in Administering Your 401(k) Plan

In addition to financial advisors, many parties are involved in the administration of 401(k) plans, such as plan sponsors (employers), plan administrators, custodians, and recordkeepers. We may collect personal information from these parties in order to help financial advisors provide you our services. For example, once you elect to participate in your employer’s 401(k) plan, your employer will share your name, email, date of birth, and salary with your plan’s financial advisor so he or she can input that information into our services and start creating your user account with us. We will then generate a unique invitation code for you so you can complete your onboarding process with us. Your plan sponsor (employer) also may provide us, through your financial advisor, your 401(k) balance and deferral rate so your financial advisor can use our services to recommend savings challenges to you.

We Collect Personal Information from Financial Institutions

At your direction, financial institutions will share certain of your financial account information with us. For example, when you opt to link your financial account to Incentive, that financial institution will share your account information with us so we can provide you with an aggregated view of your financial information, help you track your spending and help your financial advisor recommend savings challenges to you.

We Collect Personal Information from Our Service Providers

Our service providers, such as analytics providers, collect personal information through our services and often share some or all of this information with us. For example, we receive usage analysis data to improve and expand our services.

We Collect Personal Information from Publicly Available Sources

After you have registered for our services, from time to time we may obtain additional personal information about you, such as address change information, from publicly available sources to keep our records current.

We Collect Personal Information from Other Users

We may collect personal information about you from other Incentive users. For example, a spouse may link a joint bank account to Incentive, which would share with us financial information about the other spouse. In addition, for individuals that share a Incentive account with you (e.g. a family account), we may collect information about you from those individuals.

We Collect Personal Information from Social Media

If you choose to interact with us on social media, we may collect personal information about you from your social media account that you make public or share with us. We use personal information collected in connection with your social media account to communicate with you and better understand how you use our services.

Our Use of Personal Information

We use your personal information to administer your account with us, provide and improve our and our business partners’ services and products, provide you with information and advertisements based on your interests and interactions with us, contact you about our and our business partners’ services and products, coordinate with our business partners to allow them to market their products and services to you, respond to your inquiries and requests, prevent and investigate fraud, protect legal and contractual rights and comply with legal obligations.

We use personal information we collect to:

Our Disclosure of Personal Information

We disclose personal information in the following ways:

We Disclose Personal Information Within eMoney

eMoney discloses personal information across eMoney for purposes and uses consistent with this Notice. For example, we may disclose your contact information to facilitate communication between you and an eMoney customer service representative.

We Disclose Personal Information to Third Parties Involved in Administering Your 401(k) Plan

As mentioned above, many parties are involved in administering your 401(k) plan. We share your personal information with these third parties so they can administer your 401(k) plan effectively, and so we can improve our services.

For example, Incentive exists to facilitate the relationship between you and the financial advisor administering your 401(k) plan. As a result, the financial advisor has access to most information you input into our services. Your advisor will not see your transaction-level data, however, unless you affirmatively opt in to that level of access.

Our services also permit your financial advisor to share statistical and anonymized data with your employer or other parties involved in administering your 401(k) plan. For more information, please see our Anonymized and De-Identified Data section below.

We Disclose Personal Information to Our Service Providers

We engage a number of third-party service providers, vendors, consultants and other third parties to perform functions and services on our behalf and under our instruction to make our services available to you. For example, we may disclose transaction information to our payment processors to facilitate your transaction. We also may disclose additional personal information to service providers, such as application functionality partners, to enable them to provide the necessary hardware, software, functionality, networking, storage and other services we use to operate our services and maintain a high-quality experience for you. We may share your information with service providers that enable us to provide our services and help us operate our business, such as application design, sending email communications, fraud detection and prevention, customer care, or performing analytics.

We Disclose Personal Information to Our Business Partners

We coordinate with a number of third parties with whom we do business to make our and their products and services available to you. We disclose personal information to these business partners for such purposes as facilitating your purchase of a product manufactured by our business partners, or for our business partners’ own marketing purposes in compliance with applicable laws and subject to their separate privacy notices. For example, financial advisors may use personal information stored in our services to target users in certain age groups or savings brackets for their own marketing campaigns.

We may share information about you with our affiliates for any purpose identified in this Privacy Notice. We also may disclose personal information about you with third parties, such as business partners, for research, academic, marketing and/or promotional purposes. We aim to conduct such research in a way that does not allow you or any other person to be identified. For example, we may share anonymized data regarding assets under management for financial advisors or demographic data that describes the average time spent using the services. We or our third-party partners may publicly report the statistical trends of the research or analysis, but only in a way that would not allow you or any other person to be identified.

We Disclose Personal Information for Corporate Business Transactions

We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We disclose personal information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy or receivership.

We Disclose Personal Information In Accordance with Our Legal Obligations and Rights

We may disclose personal information:

We Disclose Personal Information Otherwise with Your Consent

We may disclose personal information about you to certain other third parties not described in this Notice with your consent or at your direction, including but not limited to other users (when you opt in to peer challenges), family members (when you have a joint Incentive account), and our financial planning customers (where you authorize such sharing). With your authorization, we may also share personal information with external websites or services that compile statistical trends data across the financial services industry.

Anonymized and De-Identified Data

We may collect encoded or anonymized information or statistical data (such as 401(k) plan participation rates and average account balances among 401(k) plan participants) (“Usage Data”) about a group or category of Incentive users, services, or features for research purposes. Usage Data helps us understand trends in usage of our services so that we can better consider new features or otherwise tailor our services. In addition to collecting and using Usage Data ourselves, we may share Usage Data with third parties, including our customers, affiliates, partners and service providers, for various purposes, including to help us better understand our customers’ and users’ needs and improve our services as well as for advertising and marketing purposes. For example, a financial advisor administering an employer’s 401(k) plan may use our services to generate Usage Data that shows insight into the average savings among plan participants, and may then share this Usage Data with the employer.

We may, from time to time, collect de-identified data (“De-identified Data”) from Incentive users to prepare analyses, reports, and other materials regarding (i) how users use Incentive, (ii) the types and volume of assets logged within the services, and (iii) other matters which may be useful to the financial advisor community. This De-identified Data may be combined with other users’ De-identified Data for such purposes.

Communication Preferences

If you have opted in to our marketing communications (or where permitted by law, if you have provided us or we have obtained your contact information), we may send you email messages, direct mail offers, push notifications or other communications regarding products or services depending on the method of communication selected. If you would like to opt out of getting communications from eMoney, please contact us at unsubscribe@emoneyadvisor.com or follow the unsubscribe instructions included in each marketing email. Please note that even if you opt out of receiving the foregoing communications, we may still contact you in response to any “Contact Us” requests as well as for administrative purposes.

Region-Specific Disclosures

We may choose or be required by law to provide different or additional disclosures relating to the processing of personal information about residents of certain countries and regions. Please click below to review additional disclosures applicable to you:

If you are a resident of the State of California in the United States, click here for additional California privacy disclosures.

Children’s Privacy

Our services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 18. If you are under the age of 18, do not use our services or provide us with any personal information either directly or by other means. If a child under 18 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 18, we will promptly delete that personal information.

Third Party Websites

Incentive may contain links to third party websites and include embedded content that is hosted by such third parties. We are not responsible for the privacy practices or the content of these other websites. These third parties may use web measurement and customization technologies (such as cookies) in conjunction with the provision of this content or functionality. If you use a link to another website or view an embedded video, you should consult the privacy notice for that site. We have no control over the information that is submitted to, or collected by, other websites and we are not responsible for the content of any linked site or any link contained in a linked site, or any changes or updates to such sites, or any embedded video. This Notice applies solely to information collected by us or otherwise stored in Incentive.

Changes to This Notice

We will update this Notice from time to time. When we make changes to this Notice, we will change the date at the beginning of this Notice to include the "Last Updated" date. If we make material changes to this Notice, we will notify you by email to your registered email address, by prominent posting on our services (such as by placing a conspicuous announcement of the new Notice on the Site or by presenting you with a web page containing an electronic copy of the Notice), or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification. Your only remedy, if you do not accept the terms of this Notice, is to discontinue use of the services.

How to Contact Us

If you have any questions regarding this Notice or about the privacy practices of eMoney, please contact us by email at privacy@emoneyadvisor.com using the subject title of “Privacy Policy”, by phone at 1-888-362-8482 (and mention that you have a Privacy Policy question related to Incentive) or by mail to:
Attn: Privacy Officer
eMoney Advisor, LLC
Four Radnor Corporate Center, Suite 300
100 Matsonford Road
Radnor, PA 19087

INCENTIVE PRIVACY NOTICE
ADDITIONAL CALIFORNIA PRIVACY DISCLOSURES

Last Updated: July 13, 2020

Additional California Privacy Disclosures

Personal Information Disclosures

Your Privacy Rights

Changes to These Disclosures

These Additional California Privacy Disclosures supplement the information contained in the Incentive Privacy Notice. These Disclosures apply solely to our processing of personal information of individual residents of the State of California within the scope of the California Consumer Privacy Act of 2018 (“CCPA”).

Unless otherwise expressly stated, terms in these Disclosures have the same meaning as defined in the Notice.

Personal Information Disclosures

We use the term “personal information” in these Disclosures, we mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

For the purposes of these Disclosures, the term personal information does not include:

Collection, Disclosure and Sale of Personal Information

In the last 12 months, we have collected and disclosed for a business purpose the following categories of personal information:

Category of Personal Information
Collected
Disclosed for Business Purpose
Sold*
Identifiers, such as name, email address, account username and password, security or authentication information
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California Customer Records (Cal. Civ. Code § 1798.80(e)), such as mailing address, phone number, payment information, financial account information
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Protected Classification Characteristics, such as age, date of birth, gender, and sex
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Commercial Information, such as account history, investment history, purchases, transaction information, feedback information, order details, order/product preferences, and credit information
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Biometric Information
Not collected
Not collected
Internet/Network Information, such as log file data (e.g., IP address, browser type, clickstream data) and cookies and related technology data (e.g., your usage and activity on our services)
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Geolocation Data, such as your general geographic location based on your IP address or more precise location when accessing our services through a mobile device
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No Personal Information Sold
Sensory Information, such as voice recordings from calls to customer service
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Profession/Employment Information, such as employer, department, work title, salary
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Non-Public Education Information (20 U.S.C. § 1232g, 34 C.F.R. Part 99), such as student loan information
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Other Personal Information, such as demographic information, event information, survey response information, contest entry information, user generated content and the contents of your email, text or chat with us
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Inferences, such as predictions about your interests and preferences, including order/product preferences
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*Note about “Sales”: eMoney does not “sell” information as most people would typically think of that term. However, we do permit our third-party advertising and analytics providers to collect certain personal information directly from individuals who visit or interact with our services. To the extent this practice would be deemed a “sale” by eMoney under the CCPA, please visit our Cookie Notice for more information about how third parties use cookies and related technologies to collect information automatically on our services, and the choices you have in relation to that collection.

Sources of Personal Information

As described in the Our Collection of Personal Information section of our Privacy Notice, we collect personal information directly from you when you provide it to us, automatically when you visit our services, from publicly available sources, and from service providers and other listed third parties, including third parties administering your 401(k) plan and financial institutions.

Purposes for Collecting Personal Information

We collect personal information about you for the purposes described in the Our Use of Personal Information section of our Privacy Notice.

Recipients of Personal Information

As described in the Our Disclosure of Personal Information section of our Privacy Notice, we share personal information within eMoney and with a variety of third parties.

Your Privacy Rights

As a California resident, you may be able to exercise the following rights in relation to the personal information about you that we have collected (subject to certain limitations at law):


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Knowledge

The right to request any or all of the following personal information we have collected and disclosed about you in the last 12 months:

  • The specific pieces of personal information we have collected about you;
  • The categories and specific pieces of personal information we have collected about you;
  • The categories of sources of the personal information we have collected about you;
  • The categories of personal information we have disclosed about you to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
  • The categories of personal information we have sold about you (if any), and the categories of third parties to whom this information was sold; and
  • The business or commercial purposes for collecting or, if applicable, selling personal information.

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Deletion

The right to request the deletion or erasure of personal information we have collected about you.


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Opt-out

The right to direct us not to sell personal information we have collected about you to third parties.


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Non-Discrimination

The right to be free from discrimination for exercising any of the rights described above.


The right to non-discrimination does not prohibit us from offering you certain financial incentives that may result in different prices, rates or quality levels of products or services. In addition, please note that if the exercise of the rights described above limits our ability to process personal information (such as in the case of a deletion request), we may not be able to provide access to certain of our products and services to individuals who exercise these rights, or to otherwise engage with such individuals going forward.

How to Submit a Request

For California Residents Only
To Exercise Your Right to Know or Right to Deletion, please submit a request by:

We will need to verify your identity before processing your request. In order to verify your identity, we will generally either require the successful login to your account or the matching of sufficient information you provide us to the information we maintain about you in our systems. Although we try to limit the personal information collected in connection with a request to exercise the right to know and/or the right to deletion to that personal information identified on the <<California Resident Rights Request Form>> certain requests may require us to obtain additional personal information from you. In certain circumstances, we may decline a request to exercise the right to know and/or right to deletion, particularly where we are unable to verify your identity.

To the extent Cookies and Online Ads are deemed a “Sale” of personal information under the CCPA, please visit our <<Cookie Notice>> for more information about how third parties use cookies and related technologies to collect information automatically on our services, and the choices you have in relation to that collection.

Changes to These Disclosures

We will update these Disclosures from time to time. When we make changes to these Disclosures, we will change the date at the beginning of these Disclosures to include the "Last Updated" date. If we make material changes to these Disclosures, we will notify you by email to your registered email address, by prominent posting on our services (such as by placing a conspicuous announcement of the new Disclosures on the Incentive application or by presenting you with a web page containing an electronic copy of the new Disclosures), or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification. Your only remedy, if you do not accept the terms of these Disclosures, is to discontinue use of our services.

INCENTIVE COOKIE NOTICE

Last Updated: July 13, 2020

Cookie Notice

Scope of Cookie Notice

What We Collect Using Cookies

How We Use That Information

Your Choice About Cookies

Your Choices About Online Ads

Region-Specific Disclosures

Updates to this Cookie Notice

Unless otherwise expressly stated, capitalized terms in this Cookie Notice have the same meaning as defined in the Privacy Notice.

Scope of Cookie Notice

This Cookie Notice supplements the information contained in the Privacy Notice by explaining how we and our business partners and services providers use cookies and related technologies in the course of managing and providing our services to you. It explains what these technologies are and why we use them, as well as your rights to control our use of them.

In some cases, we may use cookies and related technologies described in this Cookie Notice to collect personal information, or to collect information that becomes personal information if we combine it with other information. For more information about how we process your personal information, please review the Privacy Notice.

What we collect using cookies

We, and our third-party partners, may automatically collect certain types of usage information when you visit our services. We may collect this information through a variety of tracking technologies, including cookies, web beacons, embedded scripts, location-identifying technologies, file information, and similar technology (collectively, “cookies”). For example, we may collect information about your device and its software, such as your IP address, browser type, Internet service provider, platform type, device type, operating system, date and time stamp, and other similar information. We may collect analytics data or use third-party analytics tools such as Mixpanel to help us measure traffic and usage trends for the services and to understand more about the demographics of our users.

How we use that information

We use or may use the data collected through cookies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit our services; (b) provide and monitor the effectiveness of our services; (c) monitor metrics trends across our services such as total number of visitors, traffic, usage, and demographic patterns on our services; (d) diagnose or fix technology problems; or (e) otherwise to plan for and enhance our services. We and our advertising partners also use this information to understand your browsing activities, including across unaffiliated third-party sites, so that we can deliver ads and information about products and services that may be of interest to you.

Your choices about cookies

If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using the Site, as some features and services on our Site may not work properly. Depending on your device and operating system, you may not be able to delete or block all cookies. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.

You can learn more about Mixpanel’s by visiting Mixpanel’s privacy policy here.

Your choices about online ads

We support the self-regulatory principles for online advertising (Principles) published by the Digital Advertising Alliance (DAA). This means that we allow you to exercise choice regarding the collection of information about your online activities over time and across third-party websites for online interest-based advertising purposes. More information about these Principles can be found at www.aboutads.info/. If you want to “opt out” of receiving online interest-based advertisements on your internet browser from advertisers and third parties that participate in the DAA program and perform advertising-related services for us and our partners, please follow the instructions at www.aboutads.info/choices, or http://www.networkadvertising.org/choices/ to place an “opt-out” cookie on your device indicating that you do not want to receive interest-based advertisements. Opt-out cookies only work on the internet browser and device they are downloaded onto. If you want to opt-out of interest-based advertisements across all your browsers and devices, you will need to opt-out on each browser on each device you actively use. If you delete cookies on your device generally, you will need to opt-out again.

If you want to “opt out” of receiving online interest-based advertisements on mobile apps, please follow the instructions at http://www.aboutads.info/appchoices.

Please note that when you “opt-out” of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on our services. It means that the online ads that you do see from DAA program participants should not be based on your interests. We are not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs. In addition, third parties may still use cookies to collect information about your use of our services, including for analytics and fraud prevention as well as any other purpose permitted under the DAA’s Principles.

Region-Specific Disclosures

If you reside in the State of California in the United States, please click here for additional California-specific rights relating to the collection, use, disclosure and other processing of Personal Information through these technologies.

Updates to this Cookie Notice

We will update this Cookie Notice from time to time. When we make changes to this Cookie Notice, we will change the date at the beginning of this Cookie Notice to include the "Last Updated" date. If we make material changes to this Cookie Notice, we will notify you by email to your registered email address, by prominent posting on our services (such as by placing a conspicuous announcement of the new Cookie Notice on the Site or by presenting you with a web page containing an electronic copy of the new Cookie Notice), or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification. Your only remedy, if you do not accept the terms of this Cookie Notice, is to discontinue use of our services.

How to Contact Us

If you have any questions regarding this Notice or about the privacy practices of eMoney, please contact us by email at privacy@emoneyadvisor.com using the subject title of “Privacy Policy”, by phone at 1-888-362-8482 (and mention that you have a Privacy Policy question related to Incentive) or by mail to:
Attn: Privacy Officer
eMoney Advisor, LLC
Four Radnor Corporate Center, Suite 300
100 Matsonford Road
Radnor, PA 19087